As the Biden administration begins detailing its regulatory and enforcement priorities, it faces a new challenge on the health data privacy and security front. In University of Texas M.D. Anderson Cancer Center v. United States Department of Health and Human Services, No. 19-60226 (5th Cir. 2021), the Fifth Circuit vacated a $4.3 million penalty against […]
SEC Focused on Protecting Customer Accounts from Credential Stuffing Attacks
OCIE has released a risk alert regarding credential stuffing in the context of compliance with Regulation S-P and Regulation S-ID, and is encouraging firms to both (i) review and update their policies and procedures to address the risks associated with credential stuffing and (ii) consider proactive outreach to customers regarding measures taken to safeguard their […]
SEC Creates Event and Emerging Risk Examination Team
Following OCIE’s recent and detailed risk alert regarding the threat of ransomware, the SEC today announced that it has created the Event and Emerging Risk Examination Team (EERT) as a part of the Office of Compliance Inspections and Examinations (OCIE). The EERT will engage with registrants regarding emerging threats and current market events, to provide […]
SEC’s OCIE Issues Ransomware Risk Alert
On July 10, the SEC’s Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert noting the increasing sophistication of ransomware attacks on SEC registrants and service providers to SEC registrants. The Risk Alert is notable for its encouragement of financial services market participants more broadly and not just SEC registrants to monitor CISA […]
FTC Cautions Against Biased Outcomes in Use of AI and Algorithms
As the healthcare and financial impacts of COVID-19 continue to evolve with the global pandemic, the use of AI technology and associated risks have received greater attention. On April 8, 2020, the FTC posted an extensive summary of its recent enforcement actions, studies, and guidance regarding the use of AI tools and algorithms. The summary […]